The Kerala High Court held that police must inform an arrestee's relative or friend of the grounds of arrest before the first production before a magistrate — including in transit remand cases. The court ruled that this obligation under Section 50A CrPC (Section 47 BNSS) is not a procedural formality but a substantive constitutional right flowing from Article 22(1). Delay until after the magistrate's production violates the arrestee's fundamental right to have family notified promptly.

This ruling sharpens the distinction between two overlapping rights under Article 22: the right of the arrestee to be informed of grounds (Article 22(1)), and the right to have a chosen person informed of the arrest. Section 50A CrPC (now Section 47 BNSS) operationalises the second limb — it mandates that a nominated friend, relative, or person of interest be informed of the arrest and the place of detention as soon as practicable. The Kerala HC clarified that 'as soon as practicable' cannot mean after the first magistrate production, because by that point the most critical window — where custodial harm is statistically most likely — has already passed.

Transit remand adds a procedural layer that courts have sometimes treated as a preliminary step before 'real' production. The HC rejected that interpretation. Transit remand is still a production before a magistrate, and the constitutional obligations attach at arrest, not at the destination court.

The foundational precedent remains D.K. Basu v. State of West Bengal (1997), where the Supreme Court issued eleven binding guidelines on arrest procedure, several of which were later codified in Section 41B and 50A CrPC. The examiner tests whether aspirants can distinguish who must be informed (relative/friend vs. the arrestee herself), when (before production, not after), and under which provision (50A CrPC / 47 BNSS vs. 50 CrPC which deals with informing the arrestee herself of grounds).